CLA-2-88:OT:RR:NC:N2:206
Cody Miller
Curtiss-Wright Actuation Division
201 Old Boiling Springs Rd.
Shelby, NC 28152
RE: The tariff classification of a rotary geared actuator from the United States
Dear Mr. Miller:
In your letter dated March 20, 2026, you requested a tariff classification ruling.
The item under consideration has been identified as a Rotary Geared Actuator, Part Number 178800-xxx,
also called a flap actuator assembly, is comprised of a two-stage gear reduction system, that operates the
leading-edge flaps of the Boeing 747 aircraft. The actuator functions to transmit flap drive torque to the
linkage system of the lead edge flaps. Each unit is driven by torque from a torque tube. Torque tube rotary
motion is also transmitted through the actuator assembly to the next inline actuator. The actuator is situated
along with the bay door drives, and also can be used for controlling leading or trailing edge movements of the
aircraft. It receives power drive unit torque via assembly of shafts and joints. From a mechanical standpoint,
the actuator can be termed as an epicyclical gear reducer or compound planetary gearbox.
The 178800-xxx is purely mechanical and does not include any hydraulics, pneumatics, or electronics. It
functions based on standard gearing principles providing a specific gear ratio in a smaller form factor. It does
not rely on an external hydraulic or pneumatic power source in order to operate. It does not include a valve, a
motor or a position sensor. The actuator is situated along with the bay door drives, and also can be used for
controlling leading or trailing edge movements of the aircraft. It receives power drive unit torque via
assembly of shafts and joints. From a mechanical standpoint, the actuator can be termed as an epicyclical
gear reducer or compound planetary gearbox.
You state that the 178800-xxx actuator was manufactured in the United States; however, it is not currently in
production. It will be imported into the United States for repair or overhaul from Boeing 747 aircraft
operators in Japan, Germany, Luxembourg, Hong Kong, and other countries.
You presented two headings under the Harmonized Tariff Schedule of the United States (HTSUS) for the
rotary geared actuator: heading 8483, HTSUS, which provides for gear boxes and other speed changers,
including torque converters, and heading 8807, HTSUS, which provides for parts of aircraft. You suggest that
the rotary geared actuator is correctly classified in heading 8807, because “Note 1(l) to Section XVI excludes
articles of Section XVII, which includes aircraft and its parts, from this section. Furthermore, the Explanatory
Notes to heading 8483 exclude, "Transmission equipment of the kinds described above (gear boxes,
transmission shafts, clutches, differentials, etc.), but which are designed for use solely or principally with
vehicles or aircraft (Section XVII); it should, however, be noted that this exclusion does not apply to internal
parts of vehicle or aircraft engines - these parts remain classified in this heading."” We agree.
The applicable subheading for the Rotary Geared Actuator, Part Number 178800-xxx, will be 8807.30.0030,
HTSUS, which provides for “Parts of goods of heading 8801, 8802, or 8806: Other parts of airplanes,
helicopters or unmanned aircraft: For use in civil aircraft: Other.”. The general rate of duty will be Free.
The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience
and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided
at https://hts.usitc.gov/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents
filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact
National Import Specialist Liana Alvarez at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division